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MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge: Respondent determined deficiencies in
Federal individual income tax and additions to tax under section
6662(a)1 (accuracy-related) against petitioner as follows:
Additions to tax
Year Deficiency Sec. 6662(a)
1993 $5,471 $1,094
1994 6,969 1,394
1995 8,341 1,668
After concessions,2 the issues for decision are as follows:
1. Whether petitioner’s Schedule C activity of making
and selling videotapes (hereinafter sometimes referred to as
petitioner’s videotape activity) was “not engaged in for
profit” within the meaning of section 183 for 1993 through
1995; and
2. Whether petitioner is liable for negligence
additions to tax under section 6662(a) for 1993 through
1995.
1 Unless indicated otherwise, all section and chapter
references are to sections and chapters of the Internal Revenue
Code of 1986 as in effect for the years in issue.
2 The parties have stipulated that (1) petitioner paid or
incurred all the expenses reported on his Schedule C for each of
the years in issue, (2) these expenses are not “start-up
expenditures” within the meaning of sec. 195, and (3) if the
Court holds that petitioner’s videotape activity constituted a
trade or business, then all these expenses are deductible.
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